The Consumer Federation of America and the National Consumer Law Center (on behalf of its low-income clients) submitted comments to the Federal Reserve regarding its proposed rule for evaluating applications for new Federal Reserve payment accounts. The payment account is an alternative version of a Federal Reserve Master Account. The proposal paves the way for uninsured depositories and those not subject to federal prudential supervision to gain Fed payment service privileges. Sometimes referred to as "skinny accounts," payment accounts provide access to a subset of Fed payment services, but under stricter limitations. Unfortunately, the Payment Risk Policy payment account proposal introduces unnecessary risk into our payment system. In the comment, CFA and NCLC highlight the shortcomings in the Fed's approach to supervision to prevent money laundering and illicit finance, the lack of clear structures to prevent fraud, and the risks of incorporating uninsured depositories and digital asset providers in the banking system.